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<br />Planning Commission <br />September 15,2006 <br />Page 4 <br /> <br />Therefore, the. proposed refinement plan adoption is <br />consistent with Statewide Planning Goal 12." <br /> <br />That should be the end of the discussion. The Downtown Plan with <br />the policy language directing redesignation of the parking lot was <br />found, in the adoption of the plan, to be, consistent with Goal 12. <br /> <br />Tp.e staff or objector can make the claim that those findings on Goal <br />12 are not sufficient to justify the redesignation and rezoning of the <br />site without further traffic information. That may have been a valid <br />argument at the time of adoption of the Eugene Downtown Plan. <br />Perhaps the Council's findings on this point are not sufficient but <br />there was no objection in that regard and the plan was adopted and <br />acknowledged with the specific policy direction calling for <br />redesignation and rezoning of these sites. <br /> <br />It is important to note that the language at issue is a "policy" and not <br />one of the "implementation strategies" set forth in the Downtown Plan. <br />There are no contingencies to be satisfied prior to the policy's <br />application. Presumably, if the Downtown Plan had a Plan diagram, <br />the change would have been made at the time ofadoptio'n of the Plan. <br />Had that been the case, no additional findings on Goa112 would have <br />been necessary than were made when the text of the Plan was <br />adopted. <br /> <br />B. Goal 12 Findings. <br /> <br />Even if it were necessary to show again that the redesignation and <br />rezoning of this site is consistent with Goal 12, there is ample basis to <br />do that. <br /> <br />This site and area are subject to both the /TD Transit Oriented <br />Development Overlay Zone and the /ND Nodal Development Overlay <br />Zone. The purpose of the /TD zone states: <br /> <br />"The fTD Transit Oriented Developmen~ Overlay Zone is <br />intended to promote the creation and retention of mixed <br />land uses in areas with high potential for enhanced transit <br />and pedestrian activity. Pedestrian circulation and transit <br />access are especially important and have increased <br />.emphasis in areas with the fTD overlay zone. The <br />development standards are designed to encourage <br />